The sample forms for H-4(D)(3) & (4) table format has the principal, interest and escrow listed separately. This seems conflicting to 1026.20(d). Are we required to follow the exact table format as the model forms?
I agree the sample seems a little disconnected from the requirements, but the regulation also states it must be substantially similar. Because of this I recommend using the sample format.
1026.20(d)(3): 3) Format. (i) Except for the disclosures required by paragraph (d)(2)(i) of this section, the disclosures required by this paragraph (d) shall be provided in the form of a table and in the same order as, and with headings and format substantially similar to, forms H-4(D)(3) and (4) in appendix H to this part;
Our core provider states that the floor should not be listed because it’s not in the model form. But we have a situation…when we add our margin and our index, the rate is below our floor. The floor is actually what is determining the rate at this point. We think the notice is confusing because it tells them to add the index and the margin to get the rate.
Should we urge our core to add the floor to the notice??